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COMMENTS OF THE COUNCIL OF CITIZENS WITH LOW VISION INTERNATIONAL

Submitted by:

Patricia M. Beattie, President
Council of Citizens With Low Vision International (CCLVI)

Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Docket Number: 02-1

The Council of Citizens With Low Vision International (CCLVI), of which I am the current President, is pleased to advise you and the Access Board of our endorsement of comments submitted by American Council of the Blind (ACB) on the above proposed guidelines concerning access to public rights of way.

CCLVI specifically calls for use of the universal attention and safety color bright yellow for warning surfaces which also should be detectable underfoot and upon sound of cane contact. We believe that the use of the bright yellow color is critical for detection by the growing number of older Americans who are living long enough to experience age-related vision loss, most of which is caused by macular degeneration. Of people who attain the age of 70, one of of ten will experience macular degeneration. This condition also greatly diminishes the ability to see when there is the glare of sunshine or bright lights, or conversely, light limited by night.

CCLVI believes that it is the right of visually impaired pedestrians to have access to the same information available to other citizens--that means conveyance of information normally provided on signs and signal lights iin other ways as well--tactily or audibly.

This includes information about whether an intersection is signaled, how to locate and to activate the pedestrian button and when the walk sign comes on. With the new designs of intersections and ways of controlling traffic flow, we no longer can depend only on usual patterns or sounds of or absence of traffic flow.

CCLVI supports use of an unobtrusive tone to indicate location of a traffic signal control button, typically not to be audible beyond a distance of ten feet.

We believe that the buttons should be located sufficiently close to the crosswalk so that individual pedestrians can return to the crossing in time for change to the walk signal.

We trust that the Access Board will pay attention to the quality and content of comments submitted on these proposed guidelines, not just quantity. If some blind people don't understand the importance of these issues, that is no reason to abridge accessability and safety for the vast majority of pedestrians, including those with visual impairments, sensitivity to light or night blindness.

Thanks you for this opportunity to comment on behalf of myself and the Council of Citizens With Low Vision International.

Sincerely,

Patricia M. Beattie, President
Council of Citizens With Low Vision

Attachments:
Comments of American Council of the Blind, as endorsed by CCLVI
ACB Resolution (attached to ACB comments below)

COMMENTS OF THE AMERICAN COUNCIL OF THE BLIND
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Docket Number: 02-1
Submitted: October 24, 2002
Submitted by: Melanie Brunson, Director of Advocacy and Governmental Affairs

Mr. Scot Windley
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F. Street, N.W., Suite 1000
Washington, D.C. 20004-1111

Dear Mr. Windley,

The American Council of the Blind (ACB) is pleased to submit the following
comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which
were issued on June 17, 2002.

The American Council of the Blind (ACB) is a national membership organization
of people who are blind and visually impaired. ACB is dedicated to improving
the quality of life, equality of opportunity and independence of all people
who
have visual impairments. Its members and affiliated organizations have a long
history of commitment to the advancement of policies and programs which will
enhance the safety of pedestrians who are blind and visually impaired. For
this reason, the Draft Guidelines for Accessible Public Rights-Of-Way proposed
by the Access Board are of great interest to us.

By way of general comment, we want to let the Access Board know that we
support
the recommendations contained in this draft, and we believe that their
implementation would make travel on public ways much safer for people who are
blind and visually impaired. In the paragraphs that follow, we will highlight
some of the proposals which we believe have the greatest impact on pedestrians
who are blind and visually impaired and provide our comments thereon.

Section 1104 Curb Ramps And Blended Transitions

ACB concurs with the Access Board's recommended guidelines with regard to curb
ramps and blended transitions. Of particular interest is the requirement in
Section 1104.3.2 that detectable warning surfaces be provided wherever a curb
ramp, landing, or blended transition connects to a crosswalk. We strongly
support this requirement, and would urge the Access Board to retain it without
exception. If detectable warning surfaces are to be incorporated into the
public right-of-way in an effective manner, their application must be
consistent. We believe that their use as a means of indicating to the
visually
impaired pedestrian that they are approaching an area in which traffic is
likely to be moving is reasonable and will enhance the safety of such
pedestrians. The suggestion that detectable warnings should only be installed
where the slope of a curb ramp is 1:15 or less presupposes that the crosswalks
adjoining those ramps not covered by detectable warnings will be detectable
without them. We are not aware of any research which supports this argument.
In addition, we would point out that it requires more than a determination of
the slope of a curb ramp to determine whether one is approaching a crosswalk,
or a driveway, or some other type of space. Traffic sounds, as well as other
audible and tactile cues can influence one's decision about the nature of the
space one is about to approach, and the absence of such cues can hinder the
pedestrian's ability to accurately assess the safety of the situation. The
use
of detectable warning surfaces at such locations would provide a safe way of
indicating that the approach to a vehicular way is imminent. It provides a
definite tactile cue to the visually impaired pedestrian without in any way
supplanting his/her judgment or interfering with his/her ability to exercise
good travel skills. Therefore, ACB supports this recommendation.

Section 1105 Pedestrian Crossings

1105.4 Medians and Pedestrian Refuge Islands: ACB supports the requirement for
installation of detectable warnings on medians and pedestrian refuge islands
set forth in 1105.4.2. We concur with the Board's conclusion that an
exception is appropriate for islands where the crossing is controlled by
signals which are timed for full crossing.

1105.6 Roundabouts: ACB supports the recommendations in 1105.6.1 that barriers
be provided at roundabouts, along the street side of the sidewalk where
pedestrian crossing is prohibited. Further, ACB concurs with the Board's
recommendation that pedestrian activated traffic signals complying with
1106 be
provided for each segment of the crosswalk, including the splitter island, as
indicated in 1105.6.2. This appears to be the only feasible means of giving
blind and visually impaired pedestrians safe access to the crosswalks at
roundabouts, while causing a minimal interference with the flow of traffic on
the roundabout. It is important that at these intersections, as well as at
those intersections where a pedestrian crosswalk is provided at a right or
left
turn slip lane, a pedestrian activated traffic signal that complies with 1106
is provided for each segment of the pedestrian crosswalk, including the
island.

Section 1106 Accessible Pedestrian Signal Systems

ACB supports the requirement that each crosswalk with pedestrian signal
indication shall have a signal device which gives audible and vibrotactile
indications of the walk interval. We agree with the Board that care should be
exercised in the location of pedestrian push buttons to insure that, to the
maximum extent feasible, push buttons for accessible pedestrian signals
will be
positioned where they can be located and activated by the pedestrian while
leaving sufficient opportunity for the pedestrian to reach the curb in time to
respond to the walk interval indication.

As an aid to this process, the locator tone required by 1106.3.2 is
essential.
In addition to alerting the visually impaired pedestrian to the presence of
the
push button, it draws the attention of non-disabled pedestrians to the push
button, as well, increasing the likelihood of safer street crossings overall.
In addition, as the locator tone becomes consistently incorporated into
accessible pedestrian signal systems, the visually impaired pedestrian will
have the benefit of knowing that further accessible information is forthcoming
as a result of his/her activation of the push button. Since these tones are
only audible at close range, if the recommended guidelines are followed
correctly, they will not be disruptive to the surrounding community.
Therefore, we believe their benefits far outweigh the minimal impact they may
have on the environment.

We thank the Access Board for including specifications for pedestrian push
buttons in 1106.3.3 regarding size and contrast. These specifications are
important to facilitate their use by people who have low vision.

We believe that sections 1106.3.4 through section 1106.4.3 should be
incorporated into the Access Board's rule in their entirety. These sections
contain well-reasoned guidelines regarding the manner in which visually
impaired individuals should be able to effectively access information about
signal phases, as well as street identification and intersection design.
It is
essential that accessible pedestrian signals convey this information in a
manner that is unambiguous and we believe these guidelines will accomplish
this.

Section 1108 Detectable Warnings

ACB supports the Access Board's guidelines for the location and
installation of
detectable warning surfaces, as set forth in this section. We believe that
the
specifications contained herein minimize the accessibility concerns of persons
who have mobility impairments, while greatly enhancing the ability of visually
impaired people to access the public right-of-way in a safe manner.

As automobiles become quieter and traffic patterns become more complex, it
becomes increasingly difficult, and unsafe, to rely upon the traditional sound
of the traffic as the only means of determining when and where to cross
streets. Pedestrians who do not have visual impairments are aided by signage
and other visual cues for which people who are blind must compensate. It is
our view that the Americans with Disabilities Act requires communities to take
all reasonable steps to insure that people who are blind have access to the
same information they provide to the general public. The guidelines
recommended here represent a thoughtful and reasonable attempt to assist
communities in carrying out that responsibility and we urge the Access
Board to
incorporate these guidelines into a rule for accessible public rights-of-way.

The members of ACB passed a resolution at their convention in 2002 reiterating
their support for these guidelines, and expressing some further views with
regard to appropriate features for accessible pedestrian signals. A copy of
this resolution appears at the end of this document.

Thank you very much for your consideration.

Sincerely,
Melanie Brunson
Director of Advocacy and Governmental Affairs

AMERICAN COUNCIL OF THE BLIND

RESOLUTION 2002-24

WHEREAS, for many years, the American Council of the Blind (ACB) and its
affiliates have advocated strongly for the use of accessible pedestrian
signals, and have also been leaders in providing advice on the appropriate
standards to govern their use and installation; and

WHEREAS, subsequent to the adoption of accessible pedestrian signals standards
in the Federal Highway Administration (FHWA) Manual on Uniform Traffic Control
Devices 2000 millennium edition, revised, as well as draft guidelines
issued by
the U.S. Architectural and Transportation Barriers Compliance Board (U.S.
Access Board), many state and local jurisdictions are examining the extent to
which changes should be made in the accessible pedestrian signals guidelines
and standards contained in their traffic manuals; and

WHEREAS, ACB continues to encourage state and local jurisdictions to provide
the highest level of access to the public rights-of-way and to ensure the
safety of pedestrians;

NOW, THEREFORE, BE IT RESOLVED by the American Council of the Blind in
convention assembled this 5th day of July, 2002, in Houston, Texas, that this
organization urges state and local jurisdictions to include all of the
following requirements in their traffic manuals:

(1) Consistent with the revised FHWA standards, the state or local
jurisdiction
shall not require that organizations which represent pedestrians with
disabilities be in full agreement that there is a widespread demand for the
installation of an accessible pedestrian signal at a specific existing
signalized location in order for an accessible pedestrian signal to be
installed;

(2) Whenever the state or local jurisdiction is installing a new, or upgrading
an existing, signal, the signal shall be equipped with accessible pedestrian
features;

(3) All accessible pedestrian signals shall contain the following features;

(a) A push button with a locator tone and a tone indicating when the walk
interval is in effect.

(b) A vibrotactile device to indicate both that the walk interval is in
effect and the direction to which it applies, through the use of a vibrating
directional arrow or some other tactile indicator.

(c) Locator and walk interval tones which automatically adjust in volume in
relation to ambient noise;

(4) Activation of the pedestrian traffic signal for a period of three seconds
activates the accessible pedestrian signal; and

BE IT FURTHER RESOLVED that these standards shall not prohibit a state or
local
jurisdiction from providing additional accessible pedestrian signal
features if
requested; and

BE IT FURTHER RESOLVED that this organization transmit a copy of this
resolution to the U.S. Access Board during the public comment period on its
draft proposed guidelines on access to public rights-of-way, which ends
October
28, 2002.

Adopted.

Donna Seliger, Secretary